This Consent Decree is to reach a final settlement among the Parties with respect to the Site pursuant to CERCLA that allows the Settling Defendants and the State to make a set of cash payments, including a premium, to resolve their alleged civil liability under Sections 106, 107, and 113 of CERCLA, 42 U.S.C. ?? 9606, 9607, and 9613, for performance of investigation, cleanup, and monitoring activities at the Site, for response costs incurred and to be incurred at or
in connection with the Site, for compliance with the UAO, and for natural resource damages at the Site, thereby reducing litigation relating to the Site. The six Settling Defendants would pay a total of $54 million toward the response costs and natural resource damages associated with the Site. The State would pay an additional $100,000 to resolve its own potential CERCLA liability, as alleged in certain counterclaims asserted by some of the defendants in this case. This settlement resulted from more than two years of intensive mediation efforts conducted by the Honorable Aaron E. Goodstein. $1,375,000 (plus all accrued interest earned on $1,375,000 of the funds deposited
in the Court Registry Account) ? or 2% of the funds in the Court Registry Account ? shall be disbursed to the United States and deposited in the Lower Fox River and Green Bay Superfund Site Special Account within the EPA Hazardous Substance Superfund.